Omar Urbina Pineda - Page 6

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               Respondent accepted petitioner’s amended return and abated             
          petitioner’s tax accordingly.                                               
          C.  Final Notice Of Intent To Levy                                          
               On January 21, 2003, respondent sent petitioner a Final                
          Notice Of Intent To Levy And Notice Of Your Right To A Hearing              
          with respect to petitioner’s outstanding tax liabilities for 1999           
          and 2001.  See sec. 6330(a).                                                
               On February 19, 2003, petitioner timely filed a Form 12153,            
          Request for a Collection Due Process Hearing (CDP hearing).  On             
          the Form 12153, petitioner stated:                                          
               The IRS filed a Notice of Levy on 01/21/03, and                        
               actually mailed it on 01/31/03.  In the interim, I                     
               requested for more time to file amended returns for                    
               1999, 2000 & 2001 because of errors.[3]                                
               On April 2, 2003, respondent’s collection office forwarded             
          the Form 12153 to respondent’s Appeals Office.  The Appeals                 
          Office received the case on April 7, 2003, and assigned the case            
          to Appeals Officer Michael M. McDonnell on June 26, 2003.                   
               On July 24, 2003, the Appeals officer sent petitioner a                
          letter acknowledging that the Appeals Office had received                   
          petitioner’s case and informing petitioner that the Appeals                 
          officer would be “unable to work your case for 90 to 120 day                
          [sic].”                                                                     



               3  We note that only taxable years 1999 and 2001 are in                
          issue in the present case.                                                  





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